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INTRODUCTION… ……………………………………..…………..1
MANDATE OF PUBLIC RADIO………………………………………..…………..1
GUIDELINES……………………………………………………………….…………2
UNDERWRITING PRINCIPLES AND PROCEDURES
UNDERWRITING PRINCIPLES:
UNDERWRITING PROCEDURES:
ADVERTISING/PROMOTION PROCEDURES:
Of course, these principles and procedures fall within statutory framework (47 U. S. C. 399) and
the policies established by the Federal Communications Commission (FCC). On April 23, 1981,
the FCC adopted the Second Report and Order (BC Docket No. 21136) with new policy
concerning the non-commercial nature of public broadcasting. While on-air acknowledgment of
the funding sources is still necessary (according to Section 317(a)(1) of the Communications Act
of 1934, as amended), the 1981 FCC policy relaxed the restrictions associated with the
acknowledgments and placed the burden on the good faith of public broadcasters to prevent
abuses and to maintain the essential character of the noncommercial service.
Subsequently, in 1982 and 1984, the FCC issued reconsideration decisions which supplement the
1981 order. These decisions further clarify the underwriting policies of the Commission while
reiterating its basic reliance upon licensee discretion in making judgments on permissible credit
content and language. In 1986, the FCC issued a Public Notice addressing several specific
underwriting issues, including use of telephone numbers. In addition, there has been a series of
cases, arising out of listener complaints, in which FCC staff have interpreted and applied the
underwriting policies in the context of specific on-air credits. All of these FCC materials have
been used in developing the NPR Guidelines.
Thus, public radio is able to produce in isolation from the demands of the commercial
marketplace; is mandated to produce those programs which are educational, cultural, and
informational; and because of its noncommercial nature seeks contributions for the production of
those programs. The solicitation of these contributions and the recognition given them are
addressed in these GUIDELINES FOR UNDERWRITING OF NATIONAL PROGRAM
SERVICE PROGRAMS.
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GUIDELINES
The Guidelines for both the UNDERWRITING OF NATIONAL PROGRAM SERVICE and the
ADVERTISING AND PROMOTION OF UNDERWRITTEN PROGRAMS are presented in
two parts: Principles and Procedures. The Principles involve broad concepts that reflect the
philosophy and standards for underwriting, advertising, and promotion of the National Program
Service. The Principles form a background for the Procedures, which are specific rules
associated with the underwriting, advertising and promotion of National Program Service
programs.
National Public Radio seeks underwriting representing a broad spectrum of funding sources:
corporations, foundations, individuals, government agencies, and others.
All funding sources are considered under the “access” principle, which means that National
Public Radio has no list of sources from which funding will not be accepted. However, potential
conflict of interest and problems of listener misperception, confusion, or similar reason regarding
the funder’s role and/or influence on programming will be considered in accepting or rejecting
underwriting.1
a. Underwriters of programming in the National Program Service not only are legally
required to be identified (section 317(a)(1) of the Communications Act of 1934, as
amended), but also deserve credit for their support of public radio.
b. When a portion of a program from the National Program Service is used, underwriting
acknowledgments for that program must be aired as often as National Public Radio airs
the acknowledgment.
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The 1982 Task Force (comprising representatives from NPR member stations and NPR staff) discussed the
possibility of not allowing underwriting by corporations whose names identify a cigarette brand or alcoholic
beverage (cigarette advertising is prohibited by law) but no additional language was recommended for PRINCIPLE
A.
c. All National Program Service programming, from all sources including acquisitions, is
subject to these underwriter identification guidelines.
d. On-air announcements associated with National Program Service programs are an integral
part of the programs and must be broadcast.
e. National Public Radio management has the option of deciding on a case-by-case basis
whether insubstantial contributors should receive on-air acknowledgment. National
Public Radio maintains a list of all contributors, which is available for public inspection.
“Acknowledgments are strictly for identification of donors and should not promote the company,
products, or services of the donor. Announcements which contain comparative or qualitative
description of a product or company go beyond permissible limits.” (MM Docket 21136 Second
Report and Order, April 23, 1981, paragraph 37; Memorandum Opinion and Order, March 28,
1984, paragraph 13.)
Acknowledgments of contributions from non-profit entities are not subject to this identification-
only rule. However, NPR may impose limitations on such acknowledgments on a case-by-case
basis to avoid listener confusion or misperception.
No message or other programming material containing language that promotes the underwriter or
its business interests shall be offered at any time in exchange for the receipt, in whole or in part,
of consideration to National Public Radio, its officers, directors, or employees. (Section 399 B of
the Communications Act of 1934, as amended.)
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PRINCIPLE E. Program Content/Editorial Control
All program content and all editorial decisions related to program distribution on the National
Program Service are the sole responsibility of the National Public Radio programming staff.
Underwriting acknowledgments should not interrupt the flow of programs or distract from the
quality or sound of the programs with which they are associated.
Programs or program segments, originally produced and funded by local or regional sources and
then acquired for the National Program Service will not carry the local underwriting
acknowledgments unless the local contribution forms a significant proportion of the total
production cost of the national program.
These principles and procedures for the underwriting of programs on the National Program
Service define a style and a standard for the public radio system. Therefore stations are
encouraged to conform to these GUIDELINES when acknowledging local underwriting of
transmission or processing of a National Program Service program.
UNDERWRITING PROCEDURES:
a. The name of the underwriter’s subsidiary or bona fide operating division, or the name of
the underwriter’s parent company.
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b. The underwriter’s product or service line, identified by generic name or trade names.
Very brief descriptive phrases may be permitted to describe the product or service line
only if they are clearly objective. Usually such language would be limited to describing
one of the following characteristics of the product or service line:
(1) origin (e.g., “French wine”)
(2) intended use (e.g., “children’s clothing”)
(3) form of delivery to consumer or method of preparation (e.g., “bottled mineral
water” or “draft beer”)
(4) product content (e.g., “wool suit” or “fiberglass insulation”) without reference to
items generally assumed to be part of the product (e.g., “hamburgers with
mustard, pickles and onions”)
c. The underwriter’s corporate slogan if it identifies, but does not promote, the underwriter
or its products. The slogan must be non-promotional and value-neutral, in that it must
identify the underwriter in objective terms. Permissible non-promotional slogans often
describe aspects of an underwriter’s business, or characteristics of its product(s) in neutral
terms.
d. The location of the underwriter’s business. This may be a city or state, or a specific
address. In the alternative, it may be a generic reference to the area served (e.g., “serving
the South,” or “with stores from coast to coast”).
f. A telephone number (including an 800 number) if used for identification purposes. The
number must be stated in such a way that no call to action is implied.
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PROCEDURE 3. Placement and Usage of Acknowledgments
Stations are required to broadcast all underwriting announcements provided with the National
Program Service programs, or alternatively, member stations may have a staff announcer read the
acknowledgments in language supplied by National Public Radio. Underwriting
acknowledgments are required when a portion of a program is used.
National Public Radio will always take the responsibility of informing member stations about all
underwriting and underwriting acknowledgments on the National Program Service and will
provide related materials as necessary.
a. Music or other sounds that might be associated with an underwriter’s advertising, jingles,
or products are not encouraged.
b. Existing audio signatures used with a company’s name or logo are not encouraged.
c. Music or other sounds associated with a National Program Service program may
accompany underwriting acknowledgments.
b. Programs which might be considered controversial should include the following phrase
before the underwriting acknowledgment:
— “This program was produced by National Public Radio [or Station _____] in [city],
which is solely responsible for its content.”
c. Some programs, such as live events, may require the following disclaimer:
— “The views expressed on this program are not necessarily those of National Public
Radio, the underwriters, or the broadcast station.”
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ADVERTISING/PROMOTION PRINCIPLES AND
PROCEDURES
Advertising, publicity, and promotional materials and activities for underwritten programs of the
National Program Service may be prepared by National Public Radio, by outside production
entities from which National Public Radio acquires programs, or by the underwriters. Various
forms of print, radio, television, and other activities may all be employed for such advertising and
promotion, and they may occur at the local, regional, or national level. It is essential that all
advertising and promotion for National Program Service programs be compatible with the
noncommercial nature and image of public radio.
ADVERTISING/PROMOTION PRINCIPLES:
All advertising, publicity, and promotion for National Program Service programs should reflect
fair, equitable, and consistent standards and procedures in the following areas:
a. Identification of Underwriters
All advertising, publicity, and promotion for National Program Service programs will
identify the National Public Radio member stations in the area carrying the underwritten
program.
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All local advertising, publicity, and promotion for National Program Service programs
will identify National Public Radio member stations in the area carrying the underwritten
program.
All advertising, publicity, and promotion of National Program Service programs should avoid
references that imply commercial sponsorship, program ownership, or control of production or
program content. Choice of wording or placement of broadcast data must make a clear
separation between the subject matter of the program and the underwriter’s form of business,
product, or service.
In order to increase awareness of National Program Service programs by using limited resources
in the most effective and economical means available, all advertising and publicity
representatives involved in promoting National Program Service programs are urged to meet
together as far as possible in advance of production and/or on-air date to avoid duplication of
effort. The services of National Public Radio’s Corporate Communications may be requested to
aid in such coordination.
The responsibility for meeting the Advertising and Promotion Principles and Procedures for
Underwritten Programs on the National Program Service rests with the producing entity, which is
either National Public Radio or a producer with whom National Public Radio has a program
agreement. The accuracy of all program advertising, publicity, and promotional materials is the
responsibility of the producer and the Corporate Communications of National Public Radio. It is
required that this responsibility be so stated in any contractual agreement between a producer and
an underwriter.
ADVERTISING/PROMOTION PROCEDURES:
a. All such materials must have adequate space for station identification (call letters, logos,
and frequency) and broadcast time(s).
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b. In a market where there are several National Public Radio stations with overlapping
signals, all stations that carry an underwritten program must receive the same materials.
(1) All stations within the Metropolitan Survey Area (as defined by ARBITRON)
must be informed about such placements well in advance of the on-air date.
(2) All stations carrying the program within the Metropolitan Survey Area must be
identified, with specific broadcast time(s) included.
(1) All stations within the Metropolitan Survey Area must be informed about such
activities (e.g., press materials, celebrity tours, press parties) well in advance of the
activity.
(2) All press materials (posters, flyers, press releases) must identify all stations within
the Metropolitan Survey Area carrying the program.
All national print advertisements must include a phrase such as, “Check your local NPR station
for broadcast day and time in your area.”
On-air promotional spots prepared for broadcast by public radio or television stations must not
acknowledge program underwriters or mention an underwriter’s product.
On-air promotional spots prepared for commercial broadcasting, whether program specific or
part of an ongoing corporate advertising effort, should conform to PRINCIPLE BB above.
(Separation of Underwriter and Program Content)
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PROCEDURE 6/6. Suggested Texts for Identifying Underwriters
b. If there is more than one underwriter, each should be credited in the order of funding
level or in alphabetical order according to the discretion of the producer; e.g.:
“[Name of program] is made possible by grants from _________ and _________.”
or:
“[Name of program] is made possible, in part, by a grant from _________ with assistance
from _________.”